Clean Electricity Regulations – 5. Items That Are Not Covered By The Regulations

Clean Electricity Regulations Policy Toolkit

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Toolkit Contents

1. EXECUTIVE SUMMARY

1.1  How to use this Toolkit

2. BACKGROUND INFORMATION

2.1 The Electrical Grid

2.2 Abating Greenhouse Gas (GHG) Emissions – CCS and CCUS

3. MOST CONCERNING PROPOSED CHANGES

3.1.  Extending the time that existing unabated gas plants can continue to operate, but not proposing what this longer “End of Prescribed Life” period would be.

3.1.1. The Draft CERs approach to “EoPL” was good; Changing it is bad

3.1.2. Some of the provinces’ complaints about the Draft CERs

3.1.3. Corporations’ and System Operators’ Complaints about the Draft CERs

3.1.4. ECCC is considering extending the EoPL, but they are not telling us by how much

3.1.5. Refuting that the 20-year EoPL doesn’t allow gas plants to make enough profit

3.1.6. The “Retirement Cliff” argument fails when provinces are not willing to build renewables

3.1.7. Great Lakes offshore wind could provide enormous amounts of electricity for Ontario

3.1.8. Alberta has the greatest combined wind and solar potential in Canada

3.1.9. For the world to stay below 1.5oC of warming, Canada and other advanced countries must achieve net-zero electricity by 2035

3.1.10. A preponderance of studies find that net zero electricity in Canada is possible by 2035

3.1.11. According to General Electric, 95% abatement from gas plants using CCS is already possible

3.1.12. Alberta’s “Retirement Cliff” argument is unreasonable given the Alberta government’s prohibition on most wind power

3.1.13. Alberta is not acting in good faith and, therefore, their arguments lack merit

3.1.14. The Courts will almost certainly decide against Alberta

3.1.15.  Suggestions for your submissions about the 20-year EoPL

3.2. Extending the amount of time into the future, and thus the number, of new unabated gas plants that will benefit from less stringent EoPL provisions is bad.

3.2.1.  Again, since GE Vernova says that 95% abatement from gas plants using CCS is already possible, there is no excuse in 2024, let alone 2025 or any time thereafter, for anyone to commission a gas plant that is either not abated using CCS or that cannot be made abated by using CCS by 2035.

3.2.2  Suggestions for your submissions on extending the 1 January 2025 deadline

3.3. Replacing the 30 tCO2e/GWh emissions intensity standard with a “To Be Determined” unit-specific annual emissions limit

3.3.1. The Draft CERs – an emissions intensity limit

3.3.2 Reaction to the Draft CERs

3.3.3. The Public Update – a unit-specific emissions limit

3.3.4. Analysis

3.3.5.  Suggestions for your submissions on the emissions intensity standard

4. OTHER PROPOSED CHANGES

4.1. Offsets: Allowing companies to purchase offset credits to meet a portion of their emissions requirements

4.1.1  Suggestions for your submissions on offsets

4.2. Cogeneration: treat emissions from existing cogeneration units differently than emissions from other units, without explaining what that treatment would be

4.2.1  Suggestions for your submissions on cogeneration units

4.3. Pooling:  Allowing companies to combine the emissions limits of individual existing electricity-generating units into a pooled emissions limit.

4.3.1  Suggestions for your submissions on the pooling of units

4.4. Peaker Plants – Replacing the 450 hr limit on peaker plants with a “To Be Determined” unit-specific annual emissions limit.

4.4.1.  Suggestions for your submissions on a unit-specific emissions limit on peaker plants

4.5. Emergencies – Replacing the requirement for the federal Minister’s retroactive approval with a requirement to notify the Minister

4.5.1.  Suggestions for your submissions on the emergencies exemption

4.6. Minimum Size – Applying the CERs to units whose capacities collectively total 25 MW or more

4.6.1.  Suggestions for your submissions on units of 25 MW or less

5. ITEMS THAT ARE NOT COVERED BY THE REGULATIONS

5.1. Sector-Wide Emissions Cap

5.2. Interim targets

6. SUMMARY OF RECOMMENDATIONS – “I’m pressed for time, so please suggest what I might say in my submission!”

6.1.  Suggestions for your submissions about the 20-year EoPL

6.2  Suggestions for your submissions on extending the 1 January 2025 deadline

6.3.  Suggestions for your submissions on the emissions intensity standard

6.4  Suggestions for your submissions on offsets

6.5  Suggestions for your submissions on cogeneration units

6.6  Suggestions for your submissions on the pooling of units

6.7  Suggestions for your submissions on a unit-specific emissions limit on peaker plants

6.8  Suggestions for your submissions on the emergencies exemption

7. GLOSSARY

8. ACRONYMS

5. ITEMS THAT ARE NOT COVERED BY THE REGULATIONS

These items are noted for awareness, to help clarify what the CERs will and will not do.

5.1. Sector-Wide Emissions Cap

Neither the Draft CERs nor the Public Update put a cap on the sector’s total GHG emissions. There is nothing to stop power companies building as many fossil-fuel-fired generating units as they want. Each unit would be subject to an emissions limit, but there is no overall limit.

While the government does not explain the reason for this, it is likely to wisely avoid constraining the supply of electricity in the future. Demand for electricity will grow significantly due to electrification of transportation, buildings, and everything else as the economy transitions to net-zero by 2050. But given the scale of the transformation and the influence of several complex factors (e.g. population growth) it’s hard to predict exactly how much electricity will be needed.

The lack of a sector-wide emissions cap means there is less certainty about what the actual emissions levels will be in the future.

5.2. Interim targets

The federal government’s publicly-stated objective of a nation-wide net-zero electricity grid by 2030 is not mentioned in the Draft CERs or the accompanying RIAS. In fact, the CERs would not begin to limit the sector’s emissions until 2035. The objective of the regulations as stated in the RIAS is to, “reduce GHG (i.e. CO2) emissions from emitting electricity generation beginning in 2035.” This would, “help Canada achieve its climate change commitments towards achieving net-zero GHG emissions economy-wide by 2050.”

The Pembina Institute,[134] and other analysts and ENGOs have called for interim targets on the way to full implementation of the CERs in 2035.

Citations

[134] Jeyakumar, Binnu, Nick Schumacher, Jason Wang, Karambir Singh, and Alex Beattie, “Pembina Institute response to the proposed frame for the Clean Electricity Regulations – Submission to Environment and Climate Change Canada”, Pembina Institute, 18 August 2022. Accessed on 21 February 2024 at https://www.pembina.org/pub/pembina-institute-response-proposed-frame-clean-electricity-regulations.